Metzger, Brian

From:Sent:To:Cc:Subject:Attachments:

Sullivan, Kenneth [ks@bnl.gov] 6y)CL-Tuesday, October 20, 2009 6:00 PMFrumkin, Daniel; Metzger, BrianHiggins, James CDRAFT RAI OCNGS Ph 2 102009DRAFT RAI OCNGS Ph 2 102009.doc

Dan / Brian

Attached is a draft version of the RAIs related to the review of the Oyster Creek Phase 2 dated March 4, 2009

Would appreciate any comments or suggestions you may have so they can be incorporated into the final version

Thanks

Ken SullivanBNL

1

EneiBROOKHAVENNATIOjN-A'L LABORATORY

managed by Brookhaven Science Associatesfor the U.S. Department of Energy www.bnl.qov

Mr. Daniel FrumkinU.S. Nuclear Regulatory CommissionOffice of Nuclear Reactor RegulationDivision of Risk Assessment, Fire Protection Branch (NRR/DRA /Washington, DC 20555-0001

rgy Sciences and Technology DepartmentBuilding 130 P.O. Box 5000

Upton, NY 11973-5000Phone 631 344-7915

ksabnl.qov

October 20, 2009

Reference:

Dear Mr. Frum

JCN No. J-4242, Task Order No. 1, Exelon (Oyster Creek Nuclear Generating Station, IME0780

ikin•

By letter to the Nuclear Regulatory Commisisho(NRC) datedMMa'rch 4, 2009, Exelon GenerationCompany, LLC (the licensee), submitted a Rqu6estlfor Exempti•ronfom Title 10 of the Code of FederalRegulations, Part 50, Section IlI.G, "Fire Protetion of'S ShutdolCapability," for Oyster CreekNuclear Generating Station (designated by the' censee4 ,slthe, 'Phase 2 submittal). In accordance withthe scope of work described ir Ybf Project 1122. havevewed the request submitted by theln ain1 have r" tt,licensee andidentified a~o n ;,"o~r additional inforation, as set forth in the Enclosure.

It should be noted that thIIIIIiofth:ecnca mrtso,tshu.ee1a-s descrbennthis repoi!f esulted from a review of the technical meris ofthe licensee's March 4, 2 0dt!j bmit JQ P 11""11111115'.

t e 4 0 it pecifilally;-,tl, review was limited to an assessment of thefeasibility andrblieablity 6fthe OMAs and the adequacy of defense-in-depth provided for fire areas whichcredit the performance of OMAs a,, a means of achieving and maintaining hot shutdown conditions.Issues related to the licensee's interpret'ation of its fire protection licensing basis, were beyond the scope

of this revie wilh

If you have any me at the phone number or e-mail address indicated above.

Sincerely,

Kenneth Sullivan,Systems Engineering and Safety Analysis Group

cc: B. Grenier, NRC

1

D. DiamondJ. HigginsProject File J4242., Task 1

*1I

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2

Enclosure

II~liI,.

1111

IIIIIIt

REQUEST FOR ADDITIONAL INFORMATION

REGARDING REQUEST FOR EXEMPTION FROM10 CFR 50 APPENDIX R. SECTION III.G

OYSTER CREEK NUCLEAR GENERATING STATIONDOCKET NO. 50-219

OCNGS Phase 2 Request, NRC TAC No. ME0780

Background 1tII.

By letter to the Nuclear Regulatory Commission (NRC) datedlM arc•{,4 2009 (AgencywideDocuments Access and Management System (ADAMS) Accession NoML090640225 ), Exelon

' 1 C i k i, 4 1111fGeneration Company, LLC (the licensee), submitted a Request for Exemption from Title 10 ofthe Code of Federal Regulations, Part 50, Section IIhIG "Fire Protection of Safe Shutdown

Capability," for Oyster Creek Nuclear Generating .Saton (OCNGS).

In this submittal, Exelon is requesting that the Nuclear, Regu a1'ry Commission (NRC) approvean exemption request to allow the use of operator manu Ia1'tions (OMAs) as a means ofsatisfying the technical requirements 8f!Section III.G.2 of "p'ienaix R to 10 CFR 50 in certainsatsfyng hetecnicl rqurem nts5 tiju p '- i.9! , '1111h.

locations (i.e., fire areas or fire zones) ofthe GCNGS None of •t e OMAs identified in the

March 4, 2009 request were previously reviewed byithe Itaff . PaIgraph III.G.2 of Appendix Raameanis of ensurinPg th titoneýdat ransofeqhpendoes not identify OMAs asam redundant trains of equipment

remains free of fire damag. ,,HoWe'ver, plantswhic credit manual actions for Section IIl.G.2compliance, mayu, obu.i acton forii Neto IIvG.

compliance may obtain )specfic NRQ approvalIfo the manual action via the exemption processin accordance with'trequiremetsf 10 CFR 50.12.

This exemption re~quest diesdrIes operat, map, ual actions that were not identified in a previous

exempti.T request;,diorreviewe~dI)y the staff in a Safety Evaluation Report. The specific manualactiop~irlated to this request at, listed in Attachment 2 of the licensee's March 3, 2009

submift "• , 1

The licensee's, stated basis fo6this request is the special circumstances of 10 CFR 50.12(a)(2)(ii), which,ý states: "Application of the regulation in the particular circumstance would notserve the underlyin'yrgpurpose of the rule or is not necessary to achieve the underlying purposeof the rule" as the basis forthis request.

Under contract to the NRC, Mr. K. Sullivan, of Brookhaven National Laboratory, has beenassisting the staff in reviewing the submittal and has determined that additional information isneeded to complete his review. The requests for additional information (RAIs) described belowresulted from a review of the technical merits of the March 4, 2009 submittal.

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Requests for Additional Information

RAI-01 Circumstances for Review

The basis for this exemption request is described in Section 2.0 of Attachment 1 as follows:Modifications needed to achieve compliance with Section II.G.2 of Appendix R, (e.g., _addingfire suppression and detection systems, installing fire barriers and/or rerouting cables) represent

an unwarranted burden because they are not necessary to meet the underlying purpose of therule.,!

Provide the following relevant details to support this conclusion':'III ,II"I I th

" A technical justification of how the proposed arrangement achieves the underlying

purpose of the rule. , Il' K

* The specific requirements of II.G.2 that arenot met forfpach of the requesta

exemptions, for example, a lack of fire barriersý,spatiablseparation, automaticsuppression, etc.

" A summary of the plant specific featuresj that, compensa e.for this lack of IlI.G.2-requiredfeatures for each of the requestedli emptionsL"Eor example§, note any enhanceddefense-in-depth measures such asliack K•Onition~sources and/or combustibles, morerobust and/or suppl•,,•,tletection and s1uppression systems and the availability ofthe requestedemanual actionsI.

"• te h ica l ex ln to th t.f

ATtechnical expla '1a'on at jutifies, bow tl' roposed methods will result in a level ofprotection that is commepsurate with that intended by llI.G.2.

ii , .,

Sectionll['of Attachment ii statesthat the existing level of defense in depth is consideredaccelbtable for the majorityý Of OM.f s •ontained in the request. Section ILA of Attachment 1identifies Ithe defense-in-deptlhielements (detection, suppression, combustible loading, etc)available i•ach of the 35 fire areas / zones. However, the request does not provide asufficiently clexplanation rto pconfirm that the existing level of defense in depth is adequate tosupport the use aflMAslas a means of satisfying Section II.G.2 of Appendix R.

As described in Section 1 .8.2 of Regulatory Guide 1.189 (RG 1.189), requests to permit the useof an alternative approach (i.e., use of OMAs as a means of satisfying Section II.G.2 criteria)should include a sound technical basis clearly demonstrating that the fire protection defense-in-depth philosophy is appropriately maintained and that the exemption is technically justified.

For each fire area/zone identified in the March 4, 2009 request, provide a justification whichclearly demonstrates that the existing defense-in-depth elements (i.e., administrative controls,

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fire protection systems and features, and safe-shutdown capability) are adequate to support theuse of the requested OMAs as a means of satisfying Section III.G.2 of Appendix R.Identify all areas where you do not propose to install or improve the automatic suppressionand/or detection capabilities, and/or do not intend to implement other more restrictive fireprevention, detection, or suppression measures. For each of these areas, provide a technicaljustification to support the use of OMAs as a means of satisfying Section lII.G.2 in areas.

In addition, it is not clear how existing exemptions were considered in the evaluation of the levelof defense-in-depth provided for each fire area / zone identified in the!March 4, 2009 submittal.For example, Section III-A of Attachment 1 states that SER dated JUne 25, 1990 provided anexemption for a lack of automatic fire detection in Fire Zone T,,BrFZ••i B but the potential impactof a lack of detection on the feasibility and reliability of OMAs~lis not specifically addressed in thesubmittal li~l such

The requested responses should clearly demonstrate that defense-in-depth is pf vided such

that operators are able to safely and reliably achieve and maint•ihfhot shut down C'Pability fromthe control room. Note that it is the Nuclear Cegulatory, guaomrcn~is~sion (NRC) staffs position thatoperator manual actions alone, regardless of their feasibilitYý and reliability, do not meet the

underlying purpose of the rule without specific consideration!, f the overall concept of defense-in-depth that is being applied in a ParticUilerfirareua.

RAI-02 Ensuring ThatOne bf the iRedundant Tains Is Free of Fire Damage

Section Ill-A of Attachment 1 identifies 35 fire areas/zones that are not in compliance withAppendix R, Section IllR.2 b.cae s dow•' MAs would be required to align redundanttrain systemIs.N ach ieve'saf e snutown. Section11J-B also states that the analysis assumedworst-cas'e1 "• 1 orT fire amage requiring all of the manual actions for a particular firearea/ne to be perrormed. i

Section 1!11 2 of Appendix! i provides three options for ensuring that one of the redundanttrains of equipment remains 0 'e of fire damage. The use of Operator Manual Actions (OMAs),in lieu of the thren options pro\'Vided in III.G.2, is not explicitly included as a means ofdemonstrating com6plianceiwith Section III.G.2. Thus, systems and equipment that are notprovided with a leveliof fire protection commensurate with Section III.G.2 must be assumed tobe lost or damaged as a result of fire.

Confirm whether all redundant equipment located within a particular fire area, that is notprovided with fire protection features specified in Section III.G.2 is assumed lost or damaged

during a fire event and also confirm the time at which this equipment is assumed to be lost ordamaged.

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Section Ill-A of Attachment 1 states that the staff's approval of an exemption for a lack ofautomatic fire detection in Fire Zone TB-FZ-1 1 B was based on the following:

* the fire will not be of significant magnitude or duration,* it will be promptly extinguished by one of the two automatic sprinkler systems installed in

this fire zone, and" the flow alarms will promptly alert the fire brigade who will respond to manually fight the

fire.

As described in Section 6.2 of the June 25, 1990 SER, however,,1this list of considerations is notcomplete, as it does not include fire protection features provdifdorithe credited train of hotshutdown cables (i.e., a 1-hour rated fire wrap or relocating .... les). I

For each of the fire areas/zones identified in the March"2009 submittal, proide a crossreference between the fire area/zone and any apl)r.oed exemptions being credi4d. For eachexemption provide a concise, but accurate, listing0of fire prote~ction features identifi by thestaff in the associated SER, and identify any cases where theSlevel of fire protection describedby in the SER is no longer valid. For example, the staffosr6llIuation may have been based, inpart, on the provision of a 1-hour rated fire•b arrier wrap fdrialhhot shutdown cables but thebarrier may no longer be credited (i.e., rabandoned iniIlace). For any cases where

ththhrabd by the staff, providethe level of fire protection has changed frromlia w W I * 1C hi 4111djustification which clearly demonstrates that e curient leV6bfife safety is equivalent to thatwhich was approved by t alf"s '11! I

In~ ~ ~ ~~p adiin1tah~LSc io l!ttsothate'IER

In addition, Attachre1, Section I•states that tmanual operator actions identified in theMarch 4, 2009 submitta Iare requirddisja1result 6f%!

a) chahages to the origia'al safe shutdown anialysis, orb),jw, e implied in: the origti61safe shutdown analysis but for which an SER does not exist.

For each~fre area / zone idetifed inthe request, identify which manual actions are required asa result of (qaipr (b) above.

RAI-03 Other EVaIiatiots

Fire areas may have other exemptions or engineering evaluations that affect fire protectionsystems or safe shutdown capabilities. Provide a discussion of any other exemptions orevaluations that impact this request in any way and a justification for why such impact should beconsidered acceptable.

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RAI-04 Fire Protection System and Fire Barrier Design Criteria

Section III of Attachment 1 notes that several areas are equipped with various fire detection andsuppression systems. However, the request does not state whether the systems have beendesigned and installed in accordance with applicable design standards or requirements.

For example: Section III of Attachment 1 states that Fire Zone OB-FA-9 is protected by a fixed,total flooding, automatic Halon 1301 extinguishing system but the request does not statewhether the Halon system was installed and maintained in accordarfc'e'i particular designstandard or basis, e.g. National Fire Protection Association Standard' 12A.

Section III of Attachment 1 also states that OB-FZ-6A is p, arated frbl~ther plant areas by,s te.1,d" f illqth.

rated fire barriers. For areas such as these which credoitir[ barriers for proiding separationfrom other plant areas, state what the fire rating is for'•he barriers as well asl any penetrationsand whether they are designed and installed in accordance with a particular standard or listing.

Where fire protection features such as detection and isu ppre sioh systems and fire ratedassemblies are installed, describe the technical basis foS, such installations including theapplicable codes, standards and listingsP ilna ddition, proVicdea technical justification for anydeviations from codes, standards and lis.tigs 1!ndependent testing laboratories in the fireareas that could impact this evaluation. Lasty, po' a echnilufco for any non-rated fire protection assemblies."

I t"

Additionally, Section of Attachment 1 staes that a water curtain located in openingsbetween the 23' to5'fMelevations aJd51' to 75' elevations will provide reasonable assurance ofextinguishing any pociUlated fire)1I t of physical barriers between redundant

s d cs m i t U h[ a s ccshutdown systems is pre dde f pted, in concept, the use of an automatic firesuppression• system whicoh discharges a "water curtain" across the boundary areas separatingthe reduindant systems. Awateicurtain may aid in the extinguishment of fires. However, as

"HI• , _.ll,,,discussed in Generic Lett't(pL) 83-;3,3, the design objective of a 'water curtain" is to reduce'Ili•I,, ,i It; 11 ... . ..the spreao ases and ductsof combustion between adjoining areas, not fire

extinguishment. Provide a technical basis to support your reliance on water curtains for fireextinguishmelnt , 1

RAI-05 Time and Sdquence Assumptions

An action is considered feasible if it is shown that it is possible to be performed within theavailable time (considering relevant uncertainties in estimating the time available). The tablesprovided in Section III.B of Attachment 1 do not provide a clear link to NUREG 1852 criteria fordetermining feasibility. For example, the notes accompanying the table state that the"allowable time limit" was obtained from safe shutdown calculations. Since these calculationswere likely developed prior to the issuance of NUREG-1 852, the criteria and assumptions usedto establish these times may not be consistent with those contained in the NUREG.

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For each of the OMAs contained in this request, identify:

1) Action classification (prompt or symptom based)2) Time available - defined as the period of time from a presentation of a cue for an action

to the time of adverse consequences if the action is not taken3) Diagnosis time, defined as: The time required for an operator to examine and evaluate

data to determine the need for, and to make the decision to implement, an action 04) Implementation time; defined as: The time required by theloperator(s) to successfully

perform the manipulative aspects of an action (i.e., not thediagnosis aspectsthemselves, but typically as a result of the diagnosis aeopts),zlincluding obtaining anynecessary equipment, procedures, or other aids or de~vices; traveling to the necessarylocation; implementing the action; and checkingfthM the action has Ihad its desired effect

In addition describe the amount of time, that hasbeen assumed for detection andiassessmentof a postulated fire and provide a technical basis'fall this time , ',

The response should describe the methodology and ail assumptions used to determine eachtime. For example, it is not clear if anlysis assumel tiating time (i.e., Time 0) as the

time at which the fire is detected, the timeiat whi•hthe fire is determined to pose a threat to safeshutdown equipment, the time the reactonisiscrammmedl te time'tat a spurious signal oractuation is observed in theicontrol room, orisomeibther in the fire scenario.

For "symptom based'•1MAs, providela justificatin to support the time assumed to be availableto perform the action',iincluding confirmation that;there is adequate time for the operators todiagnose the need forie~act ýionstaveli-to action 16tation(s), perform the actions, and confirmthe expected, response befre:a firndesd cpsre equence occurs. Include a justification forassumi g 1•t'ht30ufiiptUtes would •e available to diagnose all actions.,4 ilY 'fill,,RAI-06 I"lnhiton Sources and Combuistible Fuel Load

The information•.r•ovided in Attachment 1 of the request is generally too vague to determine theadequacy of methods established to control the handling and use of combustibles and ignitionsources. For example i1for each fire area identified in the March 4, 2009 request, Attachment 1identifies the principalf tpes of combustibles (e.g., fuel oil, cable insulation, lube oil, paper,furnishings, etc.) but does not quantify the amount, room size, or location of combustibles withrespect to the cables and / or equipment of concern (i.e., those for which the exemption is beingrequested). In addition, the Attachment does not include any discussion of ignition sources inthese areas.

Provide critical details and/or assumptions regarding the fire hazards for each fire area includedin the request. This information may include, but is not limited to:

6

0 The number, type and location of potential ignition sources,

• The number and types of equipment that may exhibit high energy arcing faults, and therelationship between this equipment and any secondary combustibles,

" The quantity of cables and other secondary combustibles and their relationship topotential ignition sources, dt!Ii',

* The cable type, e.g., thermoplastic or thermoset. If ther rm'plastic cables are used,provide a discussion of self-ignited cable fires, ! i t

* Ratings for cables, e.g., IEEE-383, etc. If not rat•l•justify why fitrlespread would beassumed to be slow,

Controls on hot work and transient combustibles in the are'a, and the proxinmity ofsecondary combustibles that could be impadted'1 by a{transient fire, and

* Dimensions of the rooms includigiceilig heights."I,

RAI-07 Use of SCBAs, 'For

Clarify the use of , For exanTip', althog g1Actions 10 & 12 may require the use of a self-contained breathin44alparatus SCBA Section ilB implies that operators would not beexpected to need tMrtio!s a result, it is not clear if the discussionexpetedto eedSCBA'sjto perforrr~e-se actionstsof the use of .SCBAs is it`nd•ýdet por-ray'enwrionmental conditions operators may bereasonabýy expect eencou'nter or if the request is seeking staff approval of the rationaleprovid'e so the need f'oSCBA rhay be eliminated.

RAI-08 Fire -enarios

Attachment 1 SectionIll Band Attachment 2, identify the OMAs that may be needed as areulfieai fir, a / zone, but do not contain a suitably detailed description of the

specific fire scenarios that have been considered. Although OMAs are identified to isolatedamaged cables and reestablish control locally, no information is provided to describe theseparation between the redundant trains of cables. For example, the scenario described forAction 14 in Attachment 2 states:

This action is being performed because there is the potential that the normal ventilationsystem would not be available due to cable damage.

7

The scenario does not provide any further information regarding the specific circuits of concern,such as, cable type, location / separation, location of potential sources of fire damage, etc.. It isalso not clear where the cables are located relative to floor, walls and other trains or whetherany spatial separation exists between the two trains.

For each OMA included in this request, describe the in situ and transient fire hazards (ignitionpotential and combustibles) in the fire area that have the potential to affect the redundant trains.Provide a description of the proximity of the redundant train equipment to in situ hazards andthe spatial relationship between the redundant trains in the fire area such that if they aredamaged, manual actions would be necessary. Note, that this question is distinct from the RAIaddressing Ignition Sources and Combustible Loading, whicn focused on thecombustibles in an area, whereas, this RAI addresses the'seific relationship between ignitionsources and combustibles and the redundant trains. 1,.

RAI-09 Fire Area of Origin Re-entry , iitii,

Section 111.8. of the March 3, 2009, request states thtdepehding on the fire scenario,operators may be required to re-enter certain fire areas; 10p'clu Iding Fire Zone TB-FZ-1 10C and TB-FA-26 to perform an action following fJrievent. However,11Sections 111.C.3 and 111.C.4 state:"all operator manual actions addressed Yn'rthi b, pton rq *,taeprfomd in sepaate firzones from the initiating fire area (no re-efftky rernt ontaditiobetween Sections 111.B and,,lll;G,.

For areas where operator re-entry "',6t-fire may be required (as described in Section Ill.B):

justifcatio(a) Provide a elUiau ac essibility, availability and operability of the equipment toIli o n of, i;S lU p M n ti e d re

be operated, givewltheassumptionstatbdin'the request that all unprotected equipmentlcat6d, in a fire affed6ted area / zone is lost or damaged as a result of the fire.

(, P rovide a tabular rbss reference between all fire areas / zones that credit operator re-hli , , q11[ 1 '•It . .. .

entry to perform O s and the specific equipment to be operated. For each piece of" Ii st , '• 11l111. . .

equipment and /or ccmponent, provide a justification of why the assumption that all. i 1 1" l l tt i 1 I ! 1 1 1

equipment located i. t e fire area of origin is lost during a fire does not apply.

(c) Provide information which demonstrates that the required shutdown equipment locatedwithin the area is maintained free of fire damage and remains operable following the fireevent.

RAI-1O Information Request

Reference 4 of the March 4, 2004 request (SP-1302-06-013, Fire Protection Specification forPost-Fire Safe Shutdown Program Requirements at Oyster Creek) states that detailed

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information regarding manual actions for each fire area/zone and their associated time linestudies is contained in calculations identified in Reference 3.3.1.1. Provide the calculationsidentified in Reference 3.3.1.1 of SP-1302-06-013 and describe their applicability to the currentrequest.

RAI-11 Spurious Actuation of Containment Spray Pump

Attachment 2 states that the purpose of Action 10 (trip two breakers a t ,USS 1 B2 and removethe close fuses) is to prevent spurious start of the Containment Spra" 1PUmps. The Attachmentstates further that this action has no upper time limit and is onlylpe eformed to "ensure theiravailability for use later in the event" (i.e., cold shutdown). Coifirtrnithat spurious operation ofthe containment spray pumps would have no impact on the tated O&Atimes, expectedperformance of other shutdown systems (e.g., cause an eIectrical overlo a)or the operator'sability to achieve and maintain hot shutdown conditi•n's ii,

RAI-12 OMA Reliability "I i1i''

As stated in Section II of the request, "reliable action" is a feasible action that is analyzed anddemonstrated as being dependably re'patable within an av•ilable time, so as to avoid a definedadverse consequence, while consideringd !,aryifig) bonditions thatcould affect the available timeand/or the time to perform the action. • i. .. lllII" lUIt I.,The results of an expert elicitatio process presented: 6 App'ndix B of NUREG-1 852, conclude

factorbfti'ast 2 (i e. 100 " 'that a time margin facto t e0percent of the demonstrated time should beshown to be additionally available):' uld allow for a "high confidence of a low probability offailure" for local operatr manual actions in response to fire. As clearly stated in the NUREG,this discussion is prov ie•for guidanrce-andd is not eant to imply that a factor of 2 shouldalways be shown or ay, s• a t , 1 Is ou alwayjse such an approach. However, the availablemargin mi. Rt, e aleate sure that the requested OMAs are reliable.

In c iln 1II.B the reques states theevaluation will demonstrate that "sufficient margin" existsto perform, the individual opýrjtor manual action. The specific time margin available for eachaction is provided in Attachmient 2. Attachment 2 also provides an apparently qualitative

judgment with regard to the~adequacy of the stated time margins, stating, for example, thatadequate margin,.or,' s ffnt margin" is available. However, the submittal does not provide

sufficient detail to determYin'e the technical basis for the time margins provided in the submittal.

Provide information which demonstrates that the uncertainties described in Section 4.2.2 ofNUREG-1 852 are accounted for in the analysis of the time margins presented in Attachment 2of the March 4, 2009 request, and that the margins are sufficient to ensure that they would besuccessful a very high percentage of the time (i.e., they provide adequate time to cover potentialvariations in plant conditions and human performance). This information should clearly showthat the demonstrated time (or estimated time to complete the action based on thedemonstration), along with the extra time (i.e. margin) needed to account for factors not

9

included in the demonstration, can be enveloped by the estimate of the time available, then itcan be argued that the actions may also be performed reliably.

In addition, the March 4, 2009 request indicates that a sequential set of MOAs must beexecuted in a specified order. For example,

RAI-13 Use of MOAs in Lieu of Approved Fire Protection Features

Identify any fire areas/ zones where MOAs were used to supplant fire protection features (e.g.,1-hr rated fire barrier wrap) described by the staff in the 1986&d 411990 SERs. For eachaffected fire area/zone: l "ItiW1 l

a) Identify the applicable exemption(s) and relatec iS;R(s)b) Indicate if the exemption is still being credited inithe March 4, 2009 request.c) Provide a technical justification which clea .• monstrates that reliancln MOAs will

~ it fitnot result in a reduction of the safety marg'in established iiMthe original SEI.V!,

RAI-14 Equipment Operator LocationsII ,As discussed in NUREG-1852, the locatioi•h! r activitiet[of needOW p.ant personnel when the fire

starts could delay their participation in exec.ting theoperatomanuial actions (e.g., they may bein a location that is on the " oposit~eside of eiplant from the main control room and/or mayneed to restore certaitý equipment before beingjable to participate).~ ii.il"' n

The tables provided in'5ection Il.l ý1B theirequest ihnicate that the 2 field / equipment operatorswere assumedo be loc ,tinht., main

w ocatedin 6 mainontro lrom at the start of the fire event. Provide aal,11IR JI.ilh liý t "justificatior i~thi asumton1

RAI'V1!6alidity of Timeline, Aissumptions

Section 11I C states that the timr!eline for operator actions for the specific fire area assumes thatall potential fir6damage identified for that fire area occurs instantaneously at the point of plantshutdown. This section alsb'states that the procedural direction in ABN-29, "Plant Fires,"requires that the FSPI ,e9entered as soon as the existence of a fire is confirmed. Thesestatements appear to be contradictory and require clarification. Procedural direction toimplement ABN-29 upon confirmation of fire is consistent with NUREG-1 850 (which describesthe fire itself as the only criterion for initiating these types of actions) and recognizes the need tocomplete prompt actions well before "the point of plant shutdown" which could be considerablylater than the time the fire was first confirmed. The stated timeline assumption that fire damagewill not occur prior to the decision is made to trip the plant, is not consistent with NUREG-1 850or ABN-29 entry conditions and, therefore, is not valid. Provide a technical justification tosupport the validity of a time line that uses a different entry condition than that stated in

10

ij

NUREG-1 852 or the plant procedures ( i.e., "the point of plant shutdown" vs. "time of fireconfirmation).

In addition, Attachment 2 states that the indicated performance time of prompt actions includesthe time for operators to verify equipment response to the action (e.g. verify valve is closed).However, it is not clear how the additional time needed to take actions if the expected / desiredresponse is not obtained was incorporated into the timeline. Section III•C states that in caseswhere confirmation is required from the operator in the field to the Control Room, additional timehas been added to the estimated time to perform the operator manu'al ,action. However, theamount of time allotted for confirmation and the basis for that time!4zs'ot readily discernable.

Also, Section 11.1B of the request states that a generic tirdiagnosing prompt actions. Demonstrate that the addi4.2.2 of NUREG-1852 are enveloped by the 10 min teoperator actions. 'i JiAlso, Section 1lI.B states: "since the Control RoolI

in parallel with the safe shutdown operators performingitime was allotted for subsequent ations V,.ithe same o0of this statement, including specific examp, ofsitlsappl

Iwas allotted for.'listed in Sectionf&rdiagnosing prompt

fn a state of continual diagnosistions, no additional diagnosis" Provide additional clarification

it

Also, Provide a clear description •of how thinepotential correctivereactive actions in the ,v•,•pevdierpnpt actionl did lnot accomplish the desired result (i.e.,response not obtainedo8j) was factored into the -@MA performance time and provide the

technical basis for til"!Jtme allotted for each reactive action.

RAI-16 Time~toFire Dama ge.

The spleific location of, potential;!"targets" (i.e., cables and equipment important to post-fire safeshutdb(•'n) within each ! 'f 1he: fi " "shutdown),within each of~h tfire areasiS not included or discussed in the request. As

discussed-iin.,NUREG-1852 !ii! should;,4therefore, be assumed that the fire could start exactly inthe area where the equipment of concern would be affected at the earliest possible time. As aresult, in the absence of a d0ettailed evaluation of each fire zone which demonstrates that theprompt actions could be co~r"pleted before serious equipment damage could occur, or

information which shows that "reactive" OMAs have been appropriately incorporated into theshutdown procedures to mitigate the potential effects of fire damage, it is not clear how theprompt actions specified in the March 4, 2009 request can be credited for ensuring that onetrain of systems and equipment required to achieve and maintain hot shutdown conditionsremains free of fire damage, as specified in Section III.G.2 of the regulation.

Provide either: (1) an analysis and/or technical justification that demonstrates that the detectioncapability is sufficient to provide notification of a postulated event coincident to or beforedamage to the redundant trains of equipment occurs; or (2) provide an analysis and/or technical

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justification for scenarios where the redundant components are damaged before a fire has beenconfirmed.

RAI-17 Simulator Demonstrations

Section II1.C.4(1 1) describes simulator exercises performed to demonstrate that the operatormanual actions can be performed reliably within the times allotted by the fire safe shutdowncalculations. This section states further that Fire zones TB-FZ-1 1 D and OB-FZ-8C wereselected because they include manual actions that are prompt actionsfln other fire areas andinclude a number of common operator manual actions to performrwithin the first 45 minutes.

Since a prompt action is defined as an action that must be plegormedWithin 45 minutes, thestated basis for selecting Fire zones TB-FZ-1 1 D and requiresslparification

Also, provide a detailed justification which clearly.'demonstrates that the simulator1exercises

performed for fires in fire zones TB-FZ-1 1 D and OB'4FZ-8C adequately bound all 6dier fire

scenarios.

lll..4 11) f te rques prvid a ' 1:,In addition, provide information to demonstrate that the simulbtor exercises described in SectionII1.C.4 (11) of the request provide a realistic simulation (to thele•.ent practicable) of the entireh l '44111111 , 0'7 ," .fire-induced accident scenario, including ac actiWies. In your response,provide documentation to confirm that all actions assiateUý With detecting and diagnosing thepresence of the fire and dgnosi" te need for an'd executin the relevant manual actionswere timed during thedllonstratio.;ýlf an asp6t of the fire scenario could not be simulated,

identify it and deschbe ihow its potejiat1 impact ,ripe was predicted.

RAI-18 Diagnostic Instrumentation

Several sections of Attachment '!1state that the need for an operator to perform a required OMAcan b'e'f`readily diagnosed from the !66ntrol Room due to the numerous indications andsymptomsa.vailable.h

Section I s1.C.l1- tates that t Selire upport Procedures (FSPs) provide a symptom-basedapproach to achievi.g safe shutdown and provide the operators with information as to theavailable equipmentfinIrUding instrumentation) that can be relied upon following a fire. Becausethe operator remains within the symptom-based EOP procedure framework, the operator retainsthe ability to use any mitigating system that is unaffected by the fire.

Section II1.C.5 states that the diagnostic instruments that are available are listed at thebeginning of each FSP and that the available indications are consistent with the guidance inGeneric Letter 81-12, "Fire Protection Rule (45 FR 76602, November 19, 1980)," andInformation Notice 84-09, "Lessons Learned from NRC Inspections of Fire Protection Safe

Shutdown Systems (10 CFR 50, Appendix R)."

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The staff has defined diagnostic instrumentation in it's response to Question 5.3.9 of GenericLetter 86-10, as follows:

"Diagnostic instrumentation is instrumentation, beyond that previously identified in Attachment Ito I&E Information Notice 84-09, that is needed to assure proper actuation and functioning of

safe shutdown equipment and support equipment (e.g., flow rate, pump discharge pressure).

Therefore, it may not be sufficient to protect only the instrumentation needed to showconformance to IN 84-09 and GL 81-12; especially for symptom bas6drocedures such as theFSPs, which incorporate the EOP procedure framework for diagooIing the effects of fire sinceEOPs typically include instruments that are not evaluated for fireidamage.

Diagnostic instrumentation beyond that needed to detejnd diagnose thellocation of the fire,may not be required if the OMA is taken immedi rey~sponse to fire an "d1~s been properlyintegrated into fire response procedures. However; Happropriate diagnostic indic6ations arenecessary if the fire response procedures direct'operator actionsin response to ob'Yrvedchanges in plant conditions or other unexpected syimlptoms Of fire damage.

For each OMA that relies on controlmro'l ications to detectthe need for the action, provideinformation which demonstrates that suitible diagbostic instr'ur entation has been identified andthat the credited indications are: (a) knowrf to remain u•uiaffected by a postulated fire, (b)identified in the safe shutdowný equipment listand fir eireslonse procedures, (c) capable ofpromptly identifying the. need for thejaction withoutforcing operators to enter complex diagnosis

procedures and (d) th'a~tte action, b.ince comphee, has achieved its objective.

RAI-13 Operator Re-ent Tir~

Attachmerntllýtat'esthat the assessment of OMAs in fire-affected areas assumes that the areacan behr.6entered within 90 minut~s..

Provide 'technical justification to support this assumption including why a 90 minute period oftime is suitable for all fire areasp/ zones requiring re-entry.

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